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Broxtowe Local Plan Part 2

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Broxtowe Local Plan Part 2 BROXTOWE LOCAL PLAN PART 2 PUBLIC EXAMINATION HEARING STATEMENT IN RESPONSE TO THE INSPECTOR’S MATTERS AND QUESTIONS PAPER RESPONDENT 178 CAUNTON ENGINEERING LTD RESPONSE TO POLICY 8 MATTER 11 IS THE APPROACH TAKEN TO REVIEW AND PROTECT THE GREEN BELT JUSTIFIED, EFFECTIVE AND CONSISTENT WITH NATIONAL POLICY IN THE NPPF ? PREPARED BY Mark Flatman Managing Director iPlan Solutions Ltd These responses on behalf of Caunton Engineering Limited (Caunton) made to the specific questions raised by the Examination Inspector should be read in conjunction with the responses and associated numbered documents submitted by iPlan Solutions to the Publication Core Strategy of 3 November 2017. To assist, this letter is appended at Appendix A providing document are numerically reference numbering also referenced within this Hearing Statement. The appendices appended to this Hearing Statement are scheduled as follows; Appendix A Letter to Broxtowe BC, 3 November 2017 Appendix B Extracts from Nottinghamshire Structure Plans relating to GB Reviews Appendix C Plan demonstrating the extent of Caunton occupancy at Moorgreen Industrial Park Appendix D Calverton Parish Council v Nottingham City Council [2015] EWHC 1078 (Admin) a) Site Allocations in the Green Belt 1) Is the Green Belt review consistent with national policy in the NPPF and PPG’s and with the sequential approach set down in Policy 2 of the ACS? 1.1 It is not. PPG provides that “Reviewing a plan means undertaking an assessment to determine whether the policies need updating, which should include consideration of any changes to local circumstances and national policy….” but since the Green Belt (GB) was last reviewed the NPPF has effected a ‘sea change’ in national policy and Caunton Engineering has become a major employer whose ability to expand on-site is now being prejudiced by redundant GB designation. The Caunton site makes no material contribution to the openness of the GB (or any other purpose of the GB) and it 18/026/MJF LP Examination Representations Matter 11 December 2018 ID 178 Page 1 of 10 is necessary to remove it to prevent prejudice to sustainable economic development contrary to the strategic priorities of the Council. 1.2 GB review process within Broxtowe has been very infrequent. Appendix B hereto contains extracts from previous Nottinghamshire Structure Plans (NSP) demonstrating this. The third paragraph from the Preface to the NSP of November 1996 (for 1991-2011) states; “In his decision letter proving the 1991 Plan, the Secretary of State requested an early Review in order to assess post-2001 development land needs with regard to possible Green Belt boundary changes. Virtually no “free” land exists within the inner Green Belt boundary which is not needed to meet the development land requirements of the 1991 Structure Plan. In accordance with the wishes of the Secretary of State, the County Council has undertaken this formal Review of the 1991 Structure Plan.” 1.3 Policy 1/5 of that NSP provided guidance for GB review. The then Broxtowe Local Plan (LP) had been adopted in 1994 and had incorporated the GB boundaries established within the Nottinghamshire GB LP of June 1989. 1.4 As a consequence of the increased emphasis upon the reuse of previously developed land for housing, no GB review was done through the subsequent Broxtowe LP (adopted 2004). In 2006, the final Joint Nottinghamshire SP (JSP) was adopted. The second component of policy 1/2 of the JSP also required that LPs including GB were required to review their GB boundaries to meet the development land requirements for the JSP to 2021. This plan was revoked and superseded by the ACS of 2014, with Policy 3 of the ACS requiring a review of the GB. 1.5 As a consequence, the Broxtowe Pt2 LP publication version of September 2017 is the first occasion that a GB review has featured in Broxtowe plan making 18/026/MJF LP Examination Representations Matter 11 December 2018 ID 178 Page 2 of 10 since the boundaries were defined in the Nottinghamshire 1989 GB LP, some 28 years ago. 1.6 The current LP review does not grapple with nearly three decades of change and is not consistent with the NPPF or PPGs accordingly. Fundamentally, paragraph 160 in the NPPF 2012, that being the version under which this Examination is conducted, requires LPAs to have a clear understanding of business needs across the plan area when preparing the plan with the second bullet point requiring that local authorities should; “work closely with the business community to understand the changing needs and identify and address barriers to investment…” 1.7 The Publication Plan is deficient as the development needs of existing businesses including Caunton that will require land released from the GB during the currency of the local plan have not been accommodated. Despite representations having been made on behalf of Caunton, Broxtowe BC (BBC) has not removed the vital expansion land from the GB as requested, DOC 1. Paragraph 21 of the NPPF requires LPA’s to support existing business sectors to flexibly accommodate both identified need as well as those not specifically anticipated with the plan at the time of its preparation. Specifically the paragraph states; “Investment in business should not be over-burdened by combined requirements of planning policy expectations. Policies should recognise and seek to address potential barriers to investment….” 1.8 Caunton is one of the U.K.’s leading steelwork contractors, specialising in the design, fabrication and erection of structural steelwork. The business has made a significant investment in specialist buildings, machinery and IT at the Moorgreen Industrial Park, Appendix C and DOC 2 plan. It provides a vital, nationally important supportive role to the UK construction sector operating within the “just-in-time” production process frequently necessitating the storage of completed prefabricated elements on delivery trailers prior to being called off 18/026/MJF LP Examination Representations Matter 11 December 2018 ID 178 Page 3 of 10 for delivery to the construction project. Additionally, trial assembly and erection of finished prefabricated steel is also frequently required to check manufacturing accuracy prior to site delivery. 1.9 At present the trailer storage occurs on a part of the site known as Forest Park, which in the past has had planning permission for the erection of buildings to create circa 6500 m² of industrial floor space. Freeing this space from trailer storage will allow these industrial units to be constructed thereby facilitating the creation of further local employment opportunity. Relocation of the trailer storage to the proposed location will also assist by optimising the Caunton manufacturing workflow between its buildings to maintain its national and international competitive edge. 1.10 The Caunton business is a significant source of good quality local employment for in excess of 250 people together with the associated further additional local multiplier employment generation. Turnover has increased from £43m in 2016 to £63m in 2017. Paragraph 3.3.1 of the ACS states that the GB must be reviewed in order to meet the development requirements of the ACS and part 2 LPs to meeting the needs of existing business. 1.11 ACS Policy 2 allocates 38% of the BBC Housing distribution to the north of the Borough to the Key Settlements of Awsworth, Brinsley, Eastwood and Kimberley, some 2,350 dwellings. To achieve the sustainable development required under ACS Policy 2, sufficient complementary local employment opportunities will also be required in the north of the Borough, particularly as some existing employment land will be used to accommodate housing requirements (e.g. where there are functionally obsolete buildings and locational deficiencies making these sites no longer attractive to current employment requirements). At present, no such specific allocations are made in the plan. The continued success of Caunton is vital to the local economy and will provide an ongoing good and increasing source of local employment 18/026/MJF LP Examination Representations Matter 11 December 2018 ID 178 Page 4 of 10 opportunities for both existing and new residents. It is vitally important that it has certainty in its investment decisions. There is no other available land outside of the GB in close proximity to the existing business and relocation of the business (or indeed remote siting the trailer storage facility) would not be technically or economically feasible. 1.12 At present, the GB designation is a significant burden and potential investment barrier. Representations submitted in response to the Publication LP on behalf of Caunton followed an earlier submission to the Site Allocations and Issues and Options consultation in January 2014, Doc 4. Paragraph 2.7- 2.14 highlighted the one-dimensional residential centric failure of the LPA to consider the land requirements of significant existing employers. 1.13 Paragraph 1.1 - 1.7 of that representation explained the very specific locational proximity rational requirement for the release of 5.29Ha land from the GB at Moor Green Industrial Park identified on submitted annotated extract from the LP Proposals Plan, Doc 1. Within this area 1.68ha is proposed for use for trailer storage and trial prefabrication steel erection area. The residual 3.61ha Areas will be planted with new woodland copses creating enhanced landscape screening for both the proposed storage area and beneficially for the existing Moorgreen Industrial Park buildings as indicated on the Landscape Strategy 14-1135-001D, Doc 3, and thereby positively enhancing and creating beneficial recreational, environmental and biodiversity enhancement for 68% the land proposed for release from the GB. Following consultation with the owner of the neighbouring cottage, the scheme was refined between 2015 and 2017, Plans in Doc 2 and Doc 3 Plan. 1.14 The principal purpose of this LP objection is to highlight the lack of soundness of a plan which fails to secure the removal of the GB designation and to enable the LPA comply with its stated obligation to assist existing employers and their employment sites at Policy 4h).
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